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FORKLIFT TRUCKS Guidance Note PM28 PDF
FORKLIFT TRUCKS Guidance Note PM28 PDF
This guidance is issued by the HSE. The following guidance is not compulsory and you are free to take other
action. But if you follow the guidance you will normally be doing enough to comply with the law.
Health and safety inspectors seek to ensure compliance with the law and may refer to this guidance as illustrat-
ing good practice.
There are restrictions on the circumstances in which non-integrated working platforms can be used. Also, non-
integrated working platforms do not come under the Machinery Directive and should not be CE marked. The
guidance given in Part 1 is intended to help non-integrated working platform suppliers, hirers and users meet
their legal duties. A summary of the relevant legal requirements and how they apply to the supply and use of
non-integrated working platforms is given in Part 2.
INTRODUCTION
1. There is a variety of equipment available for work at height, including scaffolding, tower scaf-
folds, mobile elevating working platforms (MEWPs), staircases, platforms, and portable ladders. The
selection and use of an appropriate and suitable method of access will depend on the nature of the
task to be carried out, the frequency of occurrence, the duration of the work and the availability of
equipment.
2. In many workplaces people need temporary access to work at height, particularly for mainte-
nance activities. Working at height is a high-risk activity and the planning, selection and use of a
safe means of access and working area is important. This guidance assists users and suppliers to
meet their legal duties by providing advice on identifying appropriate working platform and forklift
truck combinations, how they can be used safely together and necessary design characteristics for
working platforms to provide for their safe use.
3. Primarily, forklift trucks are intended for lifting materials and not people. However, they can be
used with working platforms to allow people to work at height. It is generally accepted that, in con-
junction with a forklift truck, an integrated working platform (paragraph 8) provides a higher level of
safety than a non-integrated type (paragraphs 7 and 9). Nevertheless, a non-integrated working plat-
form may be used when it provides a safer means of access than, for example, improvised stairs or
platforms or a ladder that would otherwise be used and it is impracticable to use an integrated work-
ing platform.
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4. Examples of forklift trucks fitted with platforms are given below:-
Figure 1 – Counterbalance truck with Figure 2 - Very narrow aisle (VNA) truck with
non-integrated working platform permissioning control working platform
5. Integrated working platforms on forklift trucks, mobile elevating working platforms (MEWPs),
working platforms with independent movement (i.e. variable configurations) and working platforms
on tractor front-end loaders are not covered by this guidance.
DEFINITIONS
6. "purpose built access equipment" means equipment that, by design, is intended to be used by
people to allow them to work at height.
7. “non-integrated working platforms” are attachments for use in conjunction with forklift trucks
to elevate people so they can work at height but they have no controls in the platform that allow a
person in the platform to control the lift height of the platform or move the truck; i.e. all truck and
working platform movements are controlled by the truck operator.
8. “integrated working platforms” are attachments with controls that are linked to and isolate the
truck controls so that only a person in the platform can control the lift height of the platform and
truck movements.
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9. “permissioning control working platforms” are non-integrated working platforms with hold-
to-run controls that link to and nullify the truck lift/lower and traction controls until the controls in
the platform are actuated by a person or persons in the platform; i.e. the height of the platform or
truck movement can only occur by the truck operator operating the truck controls when the platform
controls are held by an operator in the platform.
OCCASIONAL USE
12. The Work at Height Regulations 2005, regulation 7(2)(b) places a duty on employers to select
the most suitable work equipment for the task to be carried out regardless of the duration of the task.
Nevertheless, it is foreseeable but unacceptable that people will often use unsafe methods of access
to height for short duration and occasional tasks. For example, a substantial number of serious acci-
dents occur when people are lifted on the forks or a bucket and on pallets or stillages placed on the
forks of fork lift trucks. To encourage safer working practices, in these exceptional circumstances,
occasional use of non-integrated working platforms with forklift trucks is allowed in the UK in ac-
cordance with this guidance note. This occasional use is allowed in the UK but may not be allowed
in some other EU member states. As such, there is NO free movement of non-integrated working
platforms throughout the EU and they MUST NOT be CE marked.
14. Routine or planned tasks particularly those associated with production or pre-planned activities,
such as periodic maintenance or stocktaking, are not exceptional circumstances and are thus not ex-
amples of occasional use. Generally, non-integrated work platforms do not provide as high a level of
safety as purpose built access equipment. Consequently, forklift trucks fitted with non-integrated
working platforms are not suitable for order picking, routine maintenance or the transfer of goods or
people from one level to another.
15. The design safety of industrial trucks is covered by European standards that apply to specific
truck types intended for materials handling (see Further Information). The design of MEWPS for
lifting people is covered by BS EN 280. Consequently, truck/integrated working platform combina-
tions that comply with both industrial truck and MEWP standards, or equivalent, give a higher level
of safety than non-integrated platforms and are not restricted to use in exceptional circumstances.
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PART 1 GUIDANCE
17. The weight of the platform together with its load of people, tools, materials etc. shall be not more
than half of the actual capacity of the truck (ie actual capacity for materials handling) with which it
is intended to be used at the rated load centre distance, maximum lift height and maximum out reach
in the case of telehandlers and reach trucks. The actual capacity is the capacity of the truck when
equipped with any specified attachments, such as side shift and, when carrying out maintenance
work, any items or parts placed in the platform add to the overall weight on it. For VNA trucks with
elevated operator position and secondary load elevating mechanism the maximum lift height shall be
the maximum lift height of the truck with the auxiliary mast fully raised.
Method of securing
18. The user shall ensure that, in accordance with the platform and truck manufacturer’s recommen-
dations, the platform is positively locked onto the truck with which it is to be used (paragraphs 44
and 48).
19. If the platform is fork mounted then the fork arms on the truck shall preferably extend fully into
the fork pockets. If not this is possible, they shall extend to a distance of at least 75% of the platform
length measured parallel to the axes of the fork arms.
USE
Identification
21. The user shall attach a sign to the working platform identifying the specific trucks on which it
can be used before the platform is used. Account should be taken of any attachments on the truck
when identifying the trucks with which the working platform may be used. Working platforms
should not be used on trucks that are not identified on the sign.
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Tilting mechanism, side shift and variable geometry attachments
23. Attachments and the following functions shall not be capable of movement whilst the working
platform is elevated:
- tilt or side shift
- chassis or mast levelling
- reach (reach trucks).
Truck operator
24. The truck operator shall remain at the controls of the truck while the platform is in an elevated
position.
Truck operation
25. It is essential that the truck/working platform combination shall only be used on firm, well-
maintained and level surfaces. Gradients and uneven or inconsistent ground conditions can affect the
stability of the truck.
26. For all trucks covered by this guidance (except VNA trucks fitted with an elevated operator posi-
tion and automatic speed limitation and that are operating within VNA aisles):
a. the truck should not be moved while the working platform is elevated, however, minor con-
trolled positional adjustments are acceptable if they are necessary to allow the task to be car-
ried out safely;
b. the parking brake shall be applied whenever the working platform is elevated;
c. where applicable, the transmission placed in neutral before elevating the platform;
27. If the truck/working platform combination is rated for use with the truck stabilisers and/or axle
locking deployed then they must be deployed before the platform is elevated.
Communication
28. There shall be adequate communication between the truck operator and persons on the platform
especially when raising and lowering. Hand held communication devices or a system of signals
should be used where communication is difficult. If a working platform is lifted to a height greater
than 4m above the truck operator or the working platform is used in a noisy environment then it is
likely that communication aids will be required. Extra consideration shall be given to using a per-
missioning control platform, integrated working platform or a mobile elevating work platform
(MEWP) in these circumstances.
29. When using hand signals an agreed system should be used and all involved trained in its proper
use. An example of commonly used hand signals is given in BS 7121 part 1.
30. When using hand held communication devices account shall be taken of any foreseeable hazards
due to electromagnetic compatibility.
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32. Special precautions may be necessary to ensure that personnel in the platform are not endangered
by hazards such as live electrical conductors, overhead travelling cranes, etc.
33. Overhead protection is likely to be needed if the platform is being used where there are risks
from falling objects or other overhead hazards.
Training
34. People expected to work on platforms and truck operators shall be aware of the restricted uses
given in paragraphs 13 & 14. They should be properly trained and given full instructions on safe sys-
tems of working with platforms, including the action to be taken in the event of an emergency and
the dangers associated with leaning out of the working platform.
Segregation of work
35. The working area below the work at height shall be segregated from the normal work activity.
Persons and vehicles shall be prevented from approaching the work at height activity. This may be
achieved by the use of warning cones, lights, barriers or signs as appropriate. Where necessary other
adjacent operations or activities may have to be stopped.
Maintenance
36. The platform shall be used and maintained in good working order and repair and in accordance
with the instructions provided by the working platform manufacturer.
DESIGN
Stability of the truck/working platform combination
38. Adequate stability of trucks not excluded under paragraph 37 can be achieved by meeting para-
graphs 17 & 54. If stability is not achieved in accordance with these paragraphs then the stability of
the truck/working platform combination should be verified by calculation and/or testing or equiva-
lent means.
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where a chain passes over a pulley or between moving parts of the mast or its actuating mechanism.
40. To cater for people leaning on them, the screens and guards shall be capable of withstanding,
without permanent deformation, vertical and horizontal forces of 900N applied individually and
concentrated at any point. Greater strength would be required if the screens and guards can be sub-
jected to higher forces in use or if the separation distances referred to in paragraph 41 are compro-
mised when the 900N forces are applied.
41. The screens and guards shall be of sufficient dimensions to prevent people from reaching
through, over and around them into hazardous parts on the truck. The adequacy of the screens and
guards may be assessed for particular trucks with reference to the separation (reach) distances given
in BS EN 294. Adequate information shall be provided with the working platform to allow users to
assess which trucks the working platform may be used with and to provide instructions on how to
check that adequate separation distances are provided.
Truck controls
42. The truck controls shall not be capable of being reached from the non-integrated working plat-
form. Appropriate separation (reach) distances to ensure that controls cannot be reached are given in
BS EN 294.
44. A positive locking device, e.g. behind the heels of the fork arms, shall be included on the plat-
form to retain it on the truck when in use. Any loose components associated with the locking device
shall be secured to the platform so that they cannot be mislaid when the platform is not in use.
45. The fork pockets shall fully enclose the fork arm along the full length of the platform and they
shall be fully enclosed along their underside.
46. The working platform manufacturer/supplier shall provide instructions to allow the platform to
be fitted and properly secured.
48. Where a working platform is designed for direct attachment on a truck carriage conforming to
ISO 2328, i.e. with the fork arms removed, the attachment points shall conform to the requirements
of ISO 2328.
49. If quick release bottom hooks are used they shall be designed so they cannot become detached
during operation and are retained by the platform to prevent them from becoming mislaid when it is
not in use.
50. The working platform manufacturer/supplier shall provide instructions to allow the platform to
be fitted and properly secured.
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Locating points
51. The locating (i.e. pickup) points on carriage mounted and fork arm mounted working platforms
shall be symmetrical about the centre line of the working platform.
Dimensions
53. The dimensions of the platform shall be as small as possible, compatible with the number of per-
sons that it is intended to carry and the work they are likely to undertake.
54. The platform dimension parallel to the fork arms, i.e. forward length of the platform, shall not
exceed 2 times the rated load centre distance of the truck. The width of the platform shall not exceed
the outside width over the truck load wheels by more than 250mm either side.
Floor
55. The floor of the platform shall be of adequate strength, horizontal when attached to the truck in
its elevated position, slip resistant and designed to prevent the accumulation of liquid. Any openings
in mesh floors or between the floor and toe-guards or access gates shall be dimensioned so as to pre-
vent a sphere of 15mm diameter passing through.
56. At any point the floor shall be capable of supporting a mass of 125kg applied over any area of
0.16m2 without permanent deformation and be capable of supporting, without permanent deforma-
tion, a uniform pressure of 1500N/m2 over the whole area.
58. To ensure that the rails have adequate strength, they need to be capable of withstanding, without
permanent deformation, horizontal and vertical forces of 900N concentrated at the points of least re-
sistance. If the platform is intended to carry more than 1 person at a time the same applies but the
forces should be 500N multiplied by the number of people that the platform is intended to carry; i.e.
for a platform intended to carry 3 people the forces would be 1500N. Any infill also needs to be ca-
pable of withstanding, without permanent deformation, horizontal forces of 900N concentrated at
any point on its surface.
Gate
59. Any gate provided shall open inwards, upwards or sideways and return automatically to the
closed position. It is strongly recommended that a device is provided that locks the gate automati-
cally and ensures it cannot be opened once the platform is raised. If such a device is not fitted then
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the gate shall be self-locking in the closed position.
Hand holds
60. Suitably sized and positioned handholds shall be fitted within the confines of the working plat-
form. To allow for safe use, e.g. to allow use with gloved hands, it is recommended that there is a
gap of 90mm between any handhold and the side of the platform.
Visibility
61. It is recommended that the platform is painted in a conspicuous colour.
Warning signs
62. With the exception of working platforms intended for use on VNA trucks, referred to in para-
graph 26, a permanent notice shall be fitted to the platform in a position where the fork truck opera-
tor can read it from his normal operating position when the platform is lowered stating, ‘Before ele-
vating the platform apply the parking brake and ensure the transmission is in neutral’ or equivalent.
63. A sign shall be provided on the working platform, where it can be read, informing the truck op-
erator to stay at the truck controls while the platform is in a raised position.
Identification plate
64. An identification plate shall be attached to the platform giving the following information:-
a. name and address of the platform manufacturer or authorised representative;
b. serial number and year of manufacture;
c. unladen weight of the platform and the position of the centre of gravity;
d. lost load centre (if the platform is carriage mounted);
e. maximum allowable load in kg;
f. maximum number of persons that the platform is intended to carry;
66. Information shall be supplied with the working platform to inform users that when a side shift at-
tachment or tilt mechanism is provided on the truck, to which the working platform is attached, the
side shift shall be locked in mid-position and the tilt mechanism locked so that the floor of the plat-
form is horizontal when in use. This may be achieved, for example, by fitting a device that disables
the controls to the mechanism or by mechanically locking the controls so that they cannot be inad-
vertently operated. Additional information shall be provided stating that the working platform shall
not be used on trucks with other moveable attachments unless the attachment is locked by a me-
chanical device or other means that will fail to safety when the working platform is elevated.
67. Maintenance information shall be supplied with the platform to provide for its ongoing safety in
use.
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turer’s advice.
70. The function of the permissioning control shall be clearly and durably marked with graphic sym-
bols in accordance with ISO 3287 and each symbol shall be affixed on or close to the control to
which it applies.
71. The instructions for use supplied with the working platform shall include a description of the
function and location of all controls as fitted to the platform.
72. A prominent warning sign shall be attached to the platform to indicate that the permissioning
control must be connected and tested for function before the platform is used.
74. VNA trucks with elevated operator position may only travel with the platform in the elevated po-
sition within the VNA aisles in which they normally work (see paragraph 26). Any auxiliary mast
shall be in the fully lowered position when travelling.
75. The dimensions of the platform must not reduce the working clearances of the truck within the
aisle.
76. Any rotation and mast traverse systems shall be locked in the retracted position when travelling
within the aisles in which the truck normally works.
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Directive (AUWED 89/655/EC amended by 95/63/EC) that allows the use of materials' handling
equipment not designed to lift persons to lift persons in exceptional circumstances. This means that
non-integrated working platforms do not meet the Supply of Machinery (Safety) Regulations 1992
as amended, that there is no free trade in Europe for non-integrated working platforms and that non-
integrated working platforms must not carry a CE mark. Non-integrated working platforms may be
supplied in the UK provided that they are for use only in exceptional circumstances and they meet
the requirements of S6 of the Health and Safety at Work etc Act 1974.
79. Paragraph 78 indicates that non-integrated working platforms must not carry a CE mark. Previ-
ous versions of this guidance note indicated that a CE mark was required but this is no longer appro-
priate due to the above decision. Users should be aware, therefore, that there are non-integrated
working platforms in existence that carry the CE mark. This mark should be disregarded and should
not be taken to mean that the equipment complies with a given standard. Such CE marked equipment
may, or may not, meet the requirements of this third edition of the guidance note (i.e. PM28).
80. Supply of non-integrated working platforms to other European countries is at the discretion of
the other country. Some European countries do not allow the use of non-integrated working plat-
forms. Further information is available from the relevant enforcing authorities within Europe.
81. Integrated working platforms fall within the remit of the Machinery Directive (98/37/EC). This
means that both integrated working platforms and the trucks must meet the requirements of the Sup-
ply of Machinery (Safety) Regulations 1992 and must carry the CE mark. Any integrated working
platform and truck combination intended to lift persons higher than 3m will fall within Annex IV of
the Directive and shall undergo an appropriate conformity assessment procedure involving an inde-
pendent third party approved body.
Use
Provision and Use of Work Equipment Regulations 1998 as amended
82. The Provision and Use of Work Equipment Regulations 1998 cover the selection, maintenance,
general use and training aspects of all work equipment.
83. When deciding to use a non-integrated working platform or an integrated working platform, em-
ployers must follow all the relevant requirements of PUWER. The employer must ensure that the
following requirements are met:
a. the platforms must be suitable for the purpose (integrated working platforms must be CE
marked)
b. the employer must take notice of the working conditions in which the platforms are to be
used and which may have an effect on the use of the platforms.
c. the employer must assess any additional risks to his/her workforce arising from the use of a
platform
d. the employer must make sure that the platforms are only used for operations for which they
are suitable
e. the platforms and the trucks on which they are to be used must be properly maintained
f. the platforms must only be used by persons who have received adequate training
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85. LOLER (regulation 8) requires that lifting operations are properly planned and that work is car-
ried out in a safe manner. For example, there shall be a pre-use check of the platform when fitted to
the truck and consideration given to factors such as overturning risks.
86. LOLER (regulation 9) requires lifting equipment for lifting people, which includes trucks and
working platforms used to lift people, to be thoroughly examined by a competent person at least
once every 6 months or in accordance with an examination scheme. The competent person shall be
familiar with the proper fitting of platforms to trucks, taking account of the platform manufacturer’s
recommendations, and be capable of making judgements on the integrity of the platform. He/she
shall also know how to identify defects or weaknesses which could affect the safe use of the plat-
form on the truck and shall follow an appropriate reporting procedure complying with LOLER
(regulation 10). He/she may be an in-house employee but must be sufficiently independent and im-
partial to allow objective decisions and recommendations to be made.
87. When using either a non-integrated working platform or an integrated working platform, em-
ployers must follow all the relevant requirements of LOLER. The employer must ensure that the fol-
lowing requirements are met:
a. the working platform must be of adequate strength for its intended load. Particular attention
shall be paid to the mounting or fixing points of the working platform to the truck
b. persons using the working platform or carrying out any activity from the platform must not
be at risk of being crushed, trapped or struck by the structure of the building or by the fork-
lift truck itself. Extra care shall be taken where there are overhead electrical cables or over-
head travelling cranes. Persons must not be at risk from falling from the platform.
c. the forklift truck shall be equipped with devices to prevent uncontrolled descent of the plat-
form as a result of any hydraulic system failure.
d. persons stranded at height on any platform must not be exposed to danger and must be able
to be freed.
e. the operator must be able to position the truck and the platform so that the platform and its
occupants can be lifted safely without striking any other person and without the platform fal-
ling or being released unintentionally.
f. the working platform must have its' safe working load clearly marked. The forklift truck
shall have its ' actual minimum load capacity clearly marked.
g. any operation involving the use of the working platform must be properly planned, properly
supervised and carried out in a safe manner.
h. the control position of the lift truck must be manned at all times during the lifting operation.
This may not be necessary where an integrated working platform is being used
89. Work equipment will continue to be subject to the requirements of LOLER where relevant, for
example duties to carry out a thorough examination or to mark equipment with the safe working load
etc. will still apply. Schedule 2 and 3 of WAHR will apply specifically to non-integrated and inte-
grated working platforms.
90. For more information, see INDG 401 ‘The Work at Height Regulations 2005, A Brief guide’.
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FURTHER INFORMATION
Relevant legislation
i The Health and Safety at Work etc. Act 1974
i The Management of Health and Safety at Work Regulations 1999
i The Provision and Use of Work Equipment Regulations 1998
i The Lifting Operations and Lifting Equipment Regulations 1998
i The Supply of Machinery (Safety) Regulations 1992 [as amended by Statutory Instrument 1994
No. 2063]
i Working at Height Regulations 2005
Other publications
i BS EN 1726 Part 1:1999; Safety of machinery - Industrial trucks - Self-propelled trucks up to
and including 10000kg capacity and tractors with a drawbar pull up to and including 20000N.
i BS EN 1726 Part 2:2000 Safety of industrial trucks. Self-propelled trucks up to and including 10
000 kg capacity and tractors with a drawbar pull up to and including 20 000 N. Additional re-
quirements for trucks with elevating operator positions and trucks specifically designed to travel
with elevated loads.
i BS EN 1551:1999; Safety of machinery - Industrial trucks - Self-propelled trucks over 10000kg
capacity.
i BS EN 1459:1999; Safety of machinery - Industrial trucks - Variable reach trucks
i BS EN 280:2001 Mobile elevating working platforms. Design calculations. Stability criteria.
Construction. Safety. Examinations and tests
i BS ISO 3287:1999 Powered industrial trucks - Control symbols
i BS EN 294: 1992; Safety of machinery - Safety distances to prevent danger zones being reached
by upper limbs
i BS EN 349:1993 Safety of Machinery, minimum gaps to avoid crushing of parts of the human
body
i ISO 2328: 1993; Forklift trucks: Hook-on type fork arms and fork arm carriages - Mounting di-
mensions
i BS EN 795: 1997 Protection against falls from height. Anchor devices, requirements and testing.
i BS 7121 Part 1:1989 Code of practice for the safe use of cranes, General
Web addresses
Harmonised Standards
o http://europa.eu.int/comm/enterprise/newapproach/standardization/harmstds/reflist.html
HSE website
o http://www.hse.gov.uk/
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British Standards are available from BSI Customer Services, 389 Chiswick High Road, London W4
4AL. www.bsionline.co.uk
Tel: 0208 996 9001 Fax: 0208 996 7001
While every effort has been made to ensure the accuracy of the references listed in this publication,
their future availability cannot be guaranteed.
This guidance note is produced by the Health and Safety Executive. Further information can be ob-
tained from HSE Offices or the HSE Public Enquiry Point Tel 0845 345 0055.
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